IEIM721070 | Groups of Companies

Where, within a group of companies, a company carries out activities which would bring it within the definition of an intermediary, it is that company, and not the group, which has the reporting obligation. However, in practice, if groups of companies wish to arrange their affairs so that one company takes on the responsibility for reporting for all the companies in the group, HMRC will have no objection to such an arrangement. No penalty would be due on a company that did not report, if it had not reported because another company in the group which had agreed to report for all companies in the group had in fact reported the arrangement. However, if that other company in the group failed to make a report, and a penalty was due, the penalty would be charged on the company that was the intermediary, and not on the company that had agreed to take responsibility for reporting.